Friederike, thanks for the reply. Several of the points confirm disclosure that the post asked for, and several of the direct questions remain open. I’ll take them in turn.
On the milestone-based employee incentive plans
This is the first public statement that a meaningful portion of the 250,000 GNO is committed under employee incentive plans with milestone-based disbursement tied to user growth and revenue. That is material information. It was not in GIP-128, not in any of the three quarterly reports since, not at the AMA, and not previously in this thread. It is also a significant structural fact that the DAO should have been aware of when approving a $30M per year cash budget whose Personnel Overhead and Management line items were the published compensation envelope.
A few natural follow-ups, which your reply opens and can be answered now:
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How much GNO in aggregate has been committed under these plans, measured in tokens and in notional value at the time of grant?
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What are the specific milestones, and in particular, are they measured against MAU, DAU, transaction volume, and revenue figures that the operating team itself publishes in the quarterly reports?
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What has already been disbursed, and what remains conditional?
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Are any commitments to directors, cofounders, or senior leadership, and in what proportion to rank-and-file?
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Is this program accounted for within GIP-128’s cash envelope, or is it a separate compensation stream that runs in parallel to it?
The structural point here is worth stating plainly. If a compensation plan pays in GNO conditional on user growth and revenue that are themselves reported by the plan’s beneficiaries, the design creates a direct incentive to frame and disclose those figures in ways that maximize disbursement. The Q1 2026 report is a recent example of that tension: it opens with “Q1 2026 built on the growth seen in Q4” while every user-facing metric declined, revenue was removed from disclosure, headcount was removed, and Gnosis Business active users were removed. The DAO is entitled to understand whether and how that pattern is insulated from the milestone design.
On the questions the reply does not address
Question 1 (how much of the 250k remains at Ltd, how much is committed, to whom, and under what authority) is partially confirmed but not quantified.
Question 3 (authority under which the methodology was changed) is not addressed. The reply’s own framing that earlier dashboard versions were not audited or governance-approved applies to the current version with equal force. Neither treatment has DAO approval. The question was not which dashboard version is authoritative; it was whether Ltd holds unilateral authority to reclassify its own holdings on a dashboard that exists under Noca’s GIP-148 scope. That has not been answered.
Question 4 (voting rights) is not addressed at all. If Ltd’s 250,000 GNO is circulating supply, the DAO is entitled to a direct position on whether Ltd asserts it carries governance voting rights, and if so, whether Ltd will commit not to vote it on matters in which Ltd has a direct interest, starting with the GIP-128 renewal. The absence of a position is itself a position the DAO should treat as unresolved.
On “distinct entities” and the restructure
The reply’s framing that Gnosis DAO and Gnosis Ltd are distinct entities, and that Ltd’s GNO is therefore part of active supply, is a stronger claim than the restructure supports. When GIP-128 was put to the DAO, Ltd’s legal transformation into a quasi-foundation was positioned as resolving the prior tension between equity investors and tokenholders by converting Ltd into a purely purpose-driven organization whose activity exists to serve the ecosystem. Entities can be legally distinct while one is held on purpose for the benefit of the other, and the restructure framing was the latter. If the current position is that Ltd operates with independent economic interests against the DAO to the extent of holding GNO as active supply, that is a material change in public positioning and should be acknowledged as such.
On classification vs. economic reality
The reply states that the change is a classification update and does not represent hidden value transfer or a change in economic reality. That framing is not available in both directions. A classification change that affects only the display of a number would not be worth making. A classification change that alters the NAV per GNO benchmark against which treasury performance is measured, the effective voting weight of Ltd’s holdings if treated as circulating, and the disclosed per-unit capital position of every other holder, is not economically neutral. The underlying treasury value is unchanged; the per-unit claim of every other holder is not.
On NAV methodology and Noca’s scope
Agreed that NAV depends on assumptions, particularly for illiquid and venture positions. Two distinct issues follow from that, and they should not be collapsed into one.
The first is methodological: how to count, aggregate, and mark the treasury, and how to handle standard categories like vesting contracts, ecosystem reserves, and illiquid positions. This falls squarely within Noca’s GIP-148 scope and should be published in documented form against comparable frameworks.
The second is the substantive classification of Ltd’s own holdings. That is a governance question about the relationship between Ltd and the DAO, not an execution question that a service provider can resolve by methodology choice. The natural and clean process is that Noca documents how aligned foundation or treasury-equivalent holdings are treated across the major governance-token ecosystems (the consistent pattern across Lido, Uniswap, Compound, Aave, Optimism, Arbitrum, and similar is to exclude such holdings from circulating supply), presents the options to the DAO with reasoning, and the DAO decides the substantive treatment via GIP. Noca then implements and reports. That is the scope line the mandate was built around. If the substantive classification is resolved by methodology document rather than by DAO vote, the governance question has been decided without ever being put to governance.
Until that process has run, the prior non-circulating treatment has at minimum the virtue of being consistent with how Ltd’s restructure was publicly framed and with how the broader ecosystem handles analogous holdings. On that basis, I am calling on Noca to revert the circulating supply figure on the treasury dashboard to the prior treatment while the GIP-148 methodology work is in progress. Reverting is the neutral position: it does not prejudge the substantive classification question, it preserves the status quo that was in place across months of governance discussion, and it avoids the dashboard displaying a figure that has not been governance-approved under either methodology. Maintaining the current figure requires an affirmative decision by Noca to adopt the reclassification absent a documented methodology and absent a DAO vote, which is a heavier position than a reversion.
On the burden of governance approval
The reply closes by suggesting that if the DAO prefers a different treatment or wants to anchor treasury actions to a specific framework, that should be formalized explicitly through governance. This inverts the natural burden. The prior treatment was non-circulating, in place for months, used in governance discussions, and consistent with Ltd’s post-restructure public framing. The change that requires ex-ante DAO approval is the unilateral reclassification of Ltd’s own holdings into a category that materially affects NAV measurement, buyback performance benchmarks, and voting weight. Not the reversion to the prior position.
On the buyback opener
The point that there is no GnosisDAO-approved commitment to buy back GNO until it trades at NAV is correct, and was not in dispute. The claim in the original post was that methodology changes mechanically affect the NAV benchmark against which Noca’s buyback performance is measured under its GIP-148 mandate. Noca’s winning proposal explicitly lists “GNO buyback performance disclosure” in its quarterly review scope. The absence of a formal buyback-to-NAV policy does not make the reference NAV used to measure an active buyback program a methodological free variable.